EA,
Under your interpretation two non-rated (vanilla PPL) pilots could fly with the screens up, RHS doing the VFR compliance bit, LHS "practicing" in simulated IMC, with the RHS being P1 and neither qualified to fly in IMC.
Sounds a bit iffy to me.
Where's the experts when you need them? Irv?! 2D?!
Edited cos 2D answered at the same time I posted this - do I know you 2D, your answer sounds familiar...